Attachment STA Narrative SES-STA-20180129-00069

Attachment STA Narrative

This document pretains to SES-STA-20180129-00069 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2018012900069_1331692

REQUEST FOR SPECIAL TEMPORARY AUTHORITY

By this application, SES Americom, Inc. (“SES Americom” or “SES”)

respectfully requests earth station special temporary authority (“STA”) for a period of 30 days to

permit SES to use its E110104 earth station to communicate with the ASTRA 1D spacecraft in

order to provide Tracking, Telemetry and Command (“TT&C”) while the spacecraft is
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positioned at 73° W.L. (+/- 0.10° east/west station keeping).

SES Americom’s affiliate, SES ASTRA S.A. (“SES ASTRA”), holds an

authorization from the Luxembourg Ministry of State, Office of Media and Communications2 for

the ASTRA 1D Ku-band spacecraft. SES ASTRA has requested that SES Americom assist with

providing TT&C to support the operation of ASTRA 1D at 73.0º W.L. ASTRA 1D is operating

in inclined orbit.

SES is not requesting U.S. market access or any other authorization from the

Commission in relation to the non-U.S.-licensed ASTRA 1D spacecraft, and therefore is not

providing full technical information about the ASTRA 1D satellite as part of this application.3

Details regarding the ASTRA 1D TT&C operations, including the certifications required under

1
SES previously received authority to use E110104 to provide TT&C for ASTRA 1D as
the satellite drifted from 47.3° W.L. to 72.5° W.L. See SES Americom, Inc., Call Sign E110104,
File Nos. SES-STA-20170421-00447, granted May 3, 2017 and SES-STA-20170421-00448,
granted June 7, 2017, (collectively, the “ASTRA 1D Grants”). The satellite arrived at 72.5°
W.L. in July 2017 and remained there until November 2017, when a Canadian earth station was
used to drift the satellite to 73.0° W.L. Subsequent to the relocation of the satellite to 73.0°
W.L., the Canadian earth station has been and will remain the primary TT&C facility, and SES
proposes to use the E110104 antenna only for receipt of telemetry and as a back-up for
transmission of commands if needed.
2
Ministère d’État, Service des Médias et des Communications of the Grand Duchy of
Luxembourg.
3
See Waiver Requests, infra.

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Section 25.140 of the Commission’s rules, are provided in the attachments to this request. A

basic technical description of the satellite’s operations, and an orbital debris mitigation statement

for ASTRA 1D, are provided in Attachments 2 and 3 for the Commission’s information. As

discussed below, communications with ASTRA 1D will not adversely affect the operation of any

adjacent satellites.

Grant of this request is in the public interest as the requested TT&C authority will

facilitate the safe operation of ASTRA 1D at 73.0° W.L.

No Harmful Interference to Other Spacecraft. Apart from AMC-3, located at

72.0° W.L., the nearest satellite to 73.0° W.L. with overlapping Ku-band operations is ARSAT 1

operated at 71.8° W.L. by Empresa Argentina de Soluciones Satelitales Sociedad Anónima

(ARSAT). SES has coordinated operations with ARSAT 1.

Waiver Requests. SES requests limited waivers of the Commission’s

requirements in connection with the instant request. Grant of these waivers is consistent with

Commission policy:

The Commission may waive a rule for good cause shown.
Waiver is appropriate if special circumstances warrant a
deviation from the general rule and such deviation would
better serve the public interest than would strict adherence
to the general rule. Generally, the Commission may grant a
waiver of its rules in a particular case if the relief requested
would not undermine the policy objective of the rule in
question and would otherwise serve the public interest.4

Sections 25.137 and 25.114. SES requests a waiver of Section 25.137 and the

other Commission rules cross-referenced therein. SES seeks authority in connection with

providing TT&C for ASTRA 1D, a foreign-licensed spacecraft. Section 25.137 requires that

4
PanAmSat Licensee Corp., 17 FCC Rcd 10483, 10492 (Sat. Div. 2002) (footnotes
omitted).

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applicants proposing to use U.S.-licensed earth stations to communicate with foreign-licensed

spacecraft demonstrate that the Commission’s policies for U.S. market access are satisfied.

Section 25.137 also incorporates by reference other requirements for Commission-licensed space

stations, including the obligation to file detailed technical information as specified in

Section 25.114.

Waiving Section 25.137 is consistent with the purpose of the rule, which was

intended to address situations in which a non-U.S.-licensed satellite is to be used to serve the

United States. Here, the E110104 earth station will be used solely for TT&C, not for

commercial operations. Thus, SES is not seeking authority to communicate with ASTRA 1D for

purposes of providing U.S. service within the meaning of Section 25.137.

To the extent the Commission disagrees, SES requests a waiver of the market

access and other requirements imposed in Section 25.137. Grant of a waiver will not undermine

the objectives of these requirements. The market access test described in the rule is intended to

ensure that U.S.-licensed systems have “effective competitive opportunities.”5 Because SES

Americom is not seeking authority to provide commercial services in the United States, the

requested modification does not raise any concerns about competitive equality.6

Strict adherence with Section 25.114’s requirements for detailed technical

information is also unnecessary and would be unduly burdensome. SES Americom is proposing

to use the antenna only for the limited purpose of performing TT&C for the satellite located at

73° W.L., and the relevant technical characteristics of those transmissions are provided below.

5
47 C.F.R. § 25.137(a).
6
In any event, the ASTRA 1D spacecraft at 73.0° W.L. will be operating under the
authority of Luxembourg, a WTO member country, and therefore is exempt from the
requirement to make a showing of effective competitive opportunities. 47 C.F.R. § 25.137(a)(2).

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The transmissions to the spacecraft will be conducted on a non-harmful interference basis. In

these circumstances, no valid purpose would be served by requiring a complete description of the

ASTRA 1D spacecraft.

SES Americom’s request is consistent with Commission precedent. In similar

cases in which limited communications by U.S. earth stations with a foreign-licensed satellite

were proposed, the Commission has granted operational authority without requiring a market
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access showing under Section 25.137 or full technical data as required by Section 25.114.

Section 2.106 Footnote NG52. To the extent that reception of telemetry at

11447.5 MHz and 11454 MHz constitutes a domestic (i.e., non-international) service, SES

Americom respectfully requests a limited waiver of the international-service-only restriction.8

Such a waiver is warranted in the circumstances for the limited purpose of TT&C. As the

Commission has recognized, TT&C operations generally require uplink and downlink capability

from the same earth station. For this reason, the Commission has previously granted waivers of

the international service restriction to enable TT&C to be performed in the U.S. using the

extended Ku-band frequencies.9

7
See, e.g., Hawaii Pacific Teleport, L.P., File No. SES-STA-20131030-00914 (Call Sign
E030115), granted Nov. 18, 2013 (granting authority for earth station to provide TT&C services
to ASTRA 3A operating at 176.85° W.L).; PanAmSat Licensee Corp., File Nos. SES-STA-
20090922-01211 (Call Sign E4132) & SES-STA-20090922-01212 (Call Sign E040125), both
grant-stamped Oct. 16, 2009 (granting authority for earth stations to communicate with foreign-
licensed NSS-12 spacecraft for purposes of providing launch and early operations services).
8
47 U.S.C. § 2.106 Footnote NG52.
9
See, e.g., EchoStar KuX Corporation, 20 FCC Rcd 919 (Int’l Bur. 2004) (“EchoStar 83W
Order”); EchoStar Satellite LLC, 20 FCC Rcd 930 (Int’l Bur. 2004) (“EchoStar109W Order”);
EchoStar KuX Corporation, 20 FCC Rcd 942 (2004) (“EchoStar 121W Order”). These
decisions granted waivers of the international only restriction in Footnote NG104, which has
been replaced by Footnote NG52.

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Grant of the requested waiver would not undermine the purpose of the restriction,

which is to ensure that earth station deployments in the extended Ku-band do not negatively

impact the deployment of fixed service (“FS”) in the same band or cause interference to such

operations. The telemetry downlink signals from ASTRA 1D in the extended Ku-band are

narrow in bandwidth, and will comply with the power flux density limits in the Commission’s

rules and, thus, will not interfere with FS station operations. Call sign E110104 is the only U.S.

antenna that will be used to provide TT&C to ASTRA 1D at 73.0° W.L. and will not be entitled

to interference protection from FS facilities. As a result, there will be no restrictions placed on

the deployment of FS in this band.

Section 25.210(j). The ASTRA 1D satellite is authorized by the Luxembourg

Government to operate at 73.0° W.L. within a +/- 0.1 degrees east/west station keeping box. To

the extent necessary, SES respectfully requests a waiver of Section 25.210(j) of the

Commission’s rules, which requires geostationary space stations to be operated within a +/- 0.05

degrees east/west station keeping box. The Commission has previously waived this rule based

on a finding that allowing an increased station keeping volume would “not adversely affect the

operations of other spacecraft, and would conserve fuel for future operations.”10

The facts here fit squarely within this precedent. Allowing ASTRA 1D to be

maintained within an increased station keeping volume will not harm other operators. ASTRA

1D’s station keeping volume will not overlap with that of any other satellites. In addition,

allowing ASTRA 1D to be flown at 73.0° W.L. in an expanded east-west station keeping volume

of +/-0.1 degrees will result in fuel savings for the spacecraft. This will prolong the time during

10
See, e.g., SES Americom, Inc., File Nos. SAT-MOD-20080124-00030 & SAT-AMD-
20080311-00070, grant-stamped May 19, 2008, Attachment at ¶ 1.

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which ASTRA 1D will be available to provide service. Under these circumstances, grant of any

necessary waiver of Section 25.210(j) will serve the public interest.

SES hereby certifies that no party to this application is subject to a denial of

federal benefits pursuant to Section 5301 of the Anti-Drug Abuse Act of 1988, 21 U.S.C. § 862.

For the foregoing reasons, SES respectfully requests special temporary authority

to communicate with ASTRA 1D for a period of up to 30 days in order to provide TT&C to the

satellite as described herein. Grant of the requested authority will promote safe operation of the

satellite.

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Attachment 1: TT&C Emission Characteristics

1. Earth Station Transmission Characteristics

E110104 (Manassas, VA)
Emission Designator: 800KF9D
Max EIRP: 78.8 dBW
Max EIRP Density: 54.8 dBW/4kHz

These EIRP and EIRP density levels are within the maximum EIRP and EIRP density levels
authorized in the current E110104 earth station license.
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2. TT&C Frequencies

Telecommand: 14013 MHz (omni) horizontal polarization
14493 MHz (spot) vertical polarization
Telemetry: 11447.5 MHz (spot) horizontal polarization/ (omni) vertical polarization
11454 MHz (spot, omni) vertical polarization

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In compliance with Section 25.202(g)(1) of the Commission’s rules, the proposed TT&C
operations will cause no greater interference and require no greater protection from harmful
interference than communications traffic in these bands.

Attachment 2: ASTRA 1D at 73.0° W.L.

1. Orbital Location

73.0° W.L. +/- 0.1° east-west station keeping and operating in inclined orbit

2. TT&C Frequencies

Telecommand: 14013 MHz (omni) horizontal polarization
14493 MHz (spot) vertical polarization
Telemetry: 11447.5 MHz (spot) horizontal polarization/ (omni) vertical polarization
11454 MHz (spot, omni) vertical polarization

3. Section 25.140 Certifications

Section 25.140(a)(2). SES Americom certifies that the ASTRA 1D TT&C operations in the Ku-
band have been coordinated with ARSAT 1, located at 71.8° W.L. for the telecommand
operations, and there is no frequency overlap for the telemetry. There is no frequency overlap
with Nimiq 5 located at 72.7° W.L.

Section 25.140(a)(3)(ii). SES Americom certifies that the downlink EIRP density for its
operations in the conventional and extended Ku-bands will not exceed 17 dBW/4kHz for analog
transmissions and that the associated uplink operation will not exceed applicable EIRP density
envelopes in Section 25.218 unless the non-routine uplink and/or downlink operation is
coordinated with operators of authorized co-frequency space stations at assigned locations within
six degrees of the orbital location of the proposed space station.

3. Compliance with PFD limits in 11.45-11.7 GHz

The allowable PFD levels in the 11.45-11.70 GHz bands (per 4 kHz) are defined in
Section 25.208(b)(1) of the Commission's rules for all conditions, including clear sky, and for all
methods of modulation as follows:

For angles of arrival between 0 and 5 degrees above the horizontal plane: -150 dBW/m2 in any 4
kHz band;
For angles of arrival δ (in degrees) between 5 and 25 degrees above the horizontal plane: -150 +
(δ-5)/2 dBW/m2 in any 4 kHz band; and
For angles of arrival between 25 and 90 degrees above the horizontal plane: -140 dBW/m2 in any
4 kHz band.

In order to demonstrate such compliance, the PFD levels for the telemetry carriers, are calculated
below. It can be seen from the results that compliance with the PFD levels has been achieved.

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TM Beam
Elevation angle, deg 5.0 10.0 15.0 20.0 25.0 90.0
Max. EIRP, dBW 18.0 18.0 18.0 18.0 18.0 18.0
Gain roll-off at elevation angle, dBi -20.0 -20.0 -20.0 -20.0 -20.0 0.0
EIRP at elevation angle, dBW -2.0 -2.0 -2.0 -2.0 -2.0 18.0
Carrier bandwidth, MHz 0.20 0.20 0.20 0.20 0.20 0.20
EIRP density at elevation angle dBW/4kHz -18.2 -18.2 -18.2 -18.2 -18.2 1.8
Minimum spreading loss, dB/m2 -163.3 -163.2 -163.1 -162.9 -162.8 -162.1
25.208(a) pfd limit (10.95-11.2 and 11.45-
11.7 MHz), dBW/m2/4kHz -150.0 -147.5 -145.0 -142.5 -140.0 -140.0

pfd, dBW/m2/4KHz -181.5 -181.4 -181.3 -181.1 -181.0 -160.3
Margin, dB, relative to 25.208 31.5 33.9 36.3 38.6 41.0 20.3

4. TT&C Contour Maps

SES Americom has previously provided the contour maps for the spot beam telemetry and
telecommand operations in gxt format in File No. SES-STA-20170323-00336. The antenna gain
contours for the TT&C omni beam operations are not included because the contours at 8 dB
below peak fall entirely beyond the edge of the visible Earth.1

1
See 47 C.F.R. § 25.114(c)(4)(vi)(A).

2

Attachment 3: Orbital Debris Mitigation Statement

Information regarding the orbital debris mitigation plan for ASTRA 1D is

provided below.

Spacecraft Hardware Design

The ASTRA 1D satellite was built on the proven Boeing 601 bus and was

launched in November 1994. No debris is generated during normal on-station operations, and

the spacecraft will be in a stable configuration.

The design of SES’s spacecraft locates all sources of stored energy within the

body of the structure, which provides protection from small orbital debris. SES requires that

spacecraft manufacturers assess the probability of micrometeorite damage that can cause any loss

of functionality. This probability is then factored into the ultimate spacecraft probability of

success. Any significant probability of damage would need to be mitigated in order for the

spacecraft design to meet SES’s required probability of success of the mission. SES has taken

the following steps to limit the effects of such collisions: (1) critical spacecraft components are

located inside the protective body of the spacecraft and properly shielded; and (2) where

practical, all spacecraft subsystems have redundant components to ensure no single-point

failures. The spacecraft will not use any subsystems for end-of-life disposal that are not used for

normal operations.

Minimizing Accidental Explosions

The spacecraft manufacturer generates a Failure Mode Effects and Criticality

Analysis for the spacecraft to identify all potential mission failures. This analysis indicates

failure modes, possible causes, methods of detection, and compensating features of the

spacecraft design.

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The design of the ASTRA 1D spacecraft is such that the risk of explosion is

minimized both during and after mission operations. In designing and building the spacecraft,

the manufacturer took steps to ensure that debris generation will not result from the conversion

of energy sources on board the satellite into energy that fragments the satellite. All propulsion

subsystem pressure vessels, which have high margins of safety at launch, have even higher

margins in orbit, since use of propellants and pressurants during launch decreases the propulsion

system pressure. Burst tests are performed on all pressure vessels during qualification testing to

demonstrate a margin of safety against burst. Bipropellant mixing is prevented by complete

isolation of propellant species from each other. Pressures, including a subset of the batteries,

will be monitored by telemetry.

At the end of operational life, after the satellite has reached its final disposal orbit,

all on-board sources of stored energy will be depleted or secured, excess propellant remaining in

the chemical propulsion tanks will be vented, and the batteries will be discharged.

Safe Flight Profiles

SES has assessed and limited the probability of the space station becoming a

source of debris by collisions with large debris or other operational space stations. Specifically,

SES has assessed the possibility of collision with satellites located at, or reasonably expected to

be located at, the requested orbital location or assigned in the vicinity of that location. Regarding

avoidance of collisions with controlled objects, in general, if a geosynchronous satellite is

controlled within its specified longitude and latitude station-keeping limits, collision with

another controlled object (excluding where the satellite is collocated with another object) is the

direct result of that object entering the allocated space.

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Document Created: 2018-01-29 12:24:21
Document Modified: 2018-01-29 12:24:21

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